What makes good conduct risk management information for senior managers? Part 2

Conduct Risk Management Information (MI) is increasingly important in helping inform and provide rigorous challenge to a business’s overall risk strategy, as we discussed in my previous post on Conduct Risk MI. But what are the key elements of good MI?

Certain principles are relevant for any MI: accuracy, relevance, completeness, timeliness and offering good value.

In addition, Conduct Risk MI should be:

Reflecting the conduct risk assessment and management framework

User targeted

Forward-looking

Linked to strategy

Actionable

Suitable for external view, e.g., regulators

The top key risk indicators that senior managers should see in every meeting

Many firms are looking to put qualitative measures in place to help them measure the residual level of conduct risk in the business. To do this, these firms are using Key Risk Indicators (KRIs), which are a measure used in management to indicate how risky an activity is. These KRIs allow senior management to understand the residual risk in the business, to challenge decisions and to suggest requirements for change.

The best MI will be tailored to realties of the firm, its strategy, business and risk assessment. However, here are some top KRI themes that I would expect firms to have in place;

Strategy: Three most profitable products, showing average margin and product price

Complaints: Three most complained about products, with root cause analysis

Whistleblowers: Number of whistleblowers, showing root cause of complaints

Staff Discipline: Number of complaints upheld and details of results, such as bonus decrease/termination etc.

Risk Events: Number of conduct risk events, broken down by theme

Conclusion

Conduct Risk MI for senior management should allow senior managers to have a real understanding of what is going on in the business by focusing on key qualitative measures backed by insightful commentary.

These measures may well evolve over time as the monitoring of conduct risk gains maturity, but they should remain helpful. Information for information’s sake will not help senior managers make the right decisions or aid their understanding. Meaningful Conduct Risk MI will help do both of these things, and provide value, insight and rigor to a risk management strategy.

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